While RailPAC strongly supports the goal of zero emission rail service (ZEV), RailPAC feels that the potential environmental benefits of mode shift from the highway mode to rail, especially for greenhouse gas reductions (GHG), has never been considered as an intermediate strategy by transportation planners and the California Air Resources Board (CARB). CARB appears to be solely focused on tailpipe emissions for the rail mode to the exclusion of a blended strategy. This is not surprising given CARB’s legacy of focus on automobile ground level pollution (nitrogen dioxide, particulate matter, carbon monoxide, ozone, and lead). RailPAC recommends that in the case of Greenhouse Gas (CHG, CO2) CARB should broaden its strategy.

The foundation of this recommendation is the rail mode’s dramatically higher fuel efficiency than the highway mode (by a factor of between 3 and 4 times more efficient). As a result, for any given passenger mile or ton-mile, the rail mode generates significantly less CO2 and criteria pollution than the highway mode. In the case of a Tier 4 diesel powered with renewable fuel, riders who shift from highway to rail show an 80% reduction in GHG gases. The impact is even greater if, as in the case of Amtrak’s new locomotives which are paired with battery coach tenders – battery power is used on sensitive urban segments of rail lines.

RailPAC recommends that CARB and Caltrans pivot to an alternative strategy, one that is more flexible, more incremental in nature but achievable, as pathway to reach the goal of zero emission rail operations. One key in this pivot is to recognize, incentivize and build upon the energy efficiency of the rail mode. With internal combustion automobiles and long-haul diesel trucks now likely to remain in service for decades, this is an even more relevant strategy. A carbon reduction strategy for mode shift can yield substantial near-term CO2 reduction at minimal risk.

Another factor underlying this recommendation is that California’s high priority on hydrogen power as the solution to achieving zero emissions is faltering. Given the growing issues of hydrogen fuel cost, available fuel source (natural gas with venting of CO2 to the atmosphere), hydrogen leaks, a growing body of science on leaked hydrogen as a greenhouse gas and the life cycle costs of hydrogen fuel cells, this strategy is looking more problematic. In addition, changes in Federal requirements for fuel economy and ZEV adoption mean the regulatory push for zero emissions has stalled at the interstate commerce level.

Increasing rail frequencies is the key tool to leverage the shift from the highway to the rail mode to utilize mode shift to reduce CO2 emissions. The biggest barrier to increased rail frequencies is the lack of track capacity. All the California Corridors have track capacity expansion projects environmentally cleared and partially funded, waiting for the last funding increment. Additional track capacity is also key for more aggressive rail freight initiatives, especially lower shorter-distance bulk, and container shipments (compared to high-revenue transcontinental shipments).

As a result, the task of utilizing mode shift to generate GHG savings is achievable near-term, all that is needed is the recognition by decision makers of the importance of these capacity projects in reducing VMT and associated greenhouse gas emissions.

Finally, as was noted earlier, the mode shift strategy (highway to rail) provides a pathway to achieve GHG emissions savings sooner, has no technological challenges and provides an incremental pathway to Zero Emission Rail service. This incremental pathway generates GHG savings while allowing ZEV technology to fully mature before it reaches full service. It also allows the institutional issues that delay and increase costs that prevent the widespread adoption of the global standard for zero emissions rail service, overhead catenary electrification. In addition, all the investments made as part of this mode shift strategy and the larger ridership volume are fully usable by ZEV rail network as it comes into service.